Case Digest (G.R. No. 246793)
Facts:
HCL Technologies Philippines, Inc. v. Francisco Agraviador Guarin, Jr., G.R. No. 246793, March 18, 2021, First Division, Carandang, J., writing for the Court. Petitioner HCL Technologies Philippines, Inc. (HCL) is a BPO employer; respondent Francisco A. Guarin, Jr. was hired by HCL on November 11, 2013 as a senior technical support officer assigned to the Salesforce account.Salesforce notified HCL on July 5, 2016 that it would terminate its account effective October 15, 2016. HCL informed affected employees, including Guarin, Jr., of three options: apply to Accenture, seek transfer to HCL’s Google account (two postings: Support Engineer – App Engine and Support Engineer – Compute Engine), or resign. Guarin, Jr. submitted his résumé for the Google positions after the submission deadline. HCL served a letter dated October 15, 2016 advising that his position was redundant and that his last working day would be November 15, 2016; it also filed an Establishment Termination Report with DOLE on October 11, 2016. Guarin, Jr. received P182,340.65 and signed a release, waiver, and quitclaim.
Despite those events, Guarin, Jr. filed a complaint for illegal dismissal, monetary claims, moral and exemplary damages, and attorney’s fees against HCL and certain officers. The Labor Arbiter (LA) rendered a Decision on June 30, 2017 declaring Guarin, Jr. illegally dismissed, awarding backwages, moral and exemplary damages (P50,000 each), and attorney’s fees (10% of the award), and denying other claims for lack of proof. The LA found HCL complied with notice and separation pay but failed to show good faith and fair criteria for redundancy and found the quitclaim vitiated by fraud or mistake; reinstatement was not ordered because Guarin, Jr. already received separation pay.
Both parties appealed to the National Labor Relations Commission (NLRC). In its October 30, 2017 Decision, the NLRC partially granted the appeals, modified the monetary award computation (totaling Php443,975.40), concurred that procedural notice and separation pay were met but held HCL failed to prove good faith and fair criteria and that the quitclaim was not voluntarily executed; it denied moral/exemplary damages and attorney’s fees for lack of bad faith and declined reinstatement but awarded backwages until finality. HCL’s motion for reconsideration was denied.
HCL filed a petition for certiorari with the Court of Appeals (CA). The CA in its January 29, 2019 Decision affirmed the NLRC but modified that monetary awards shall earn 6% interest per annum from finality until full satisfaction; the CA agreed that HCL satisfied only the procedural requisites and that the quitclaim was procured by fraud or deceit. HCL’s motion for reconsideration before the CA was denied.
HCL then filed a Petition for Review on Certiorari with this Court (Rule 45) to assail the CA’s Decision and Resolution, arguing it complied...(Pro-only)
Issues:
- Did the Court of Appeals err in affirming the NLRC and the Labor Arbiter that respondent Francisco A. Guarin, Jr. was illegally dismis...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)